The United States Corporate Transparency Act (the “CTA”) was passed by the United States Congress in early 2023 to improve financial transparency and increase the effectiveness of anti-money laundering efforts. However, the CTA will also impose several obligations on millions of entities (each, a “Reporting Company”), including private fund advisers and the private funds they advise (subject to certain exceptions as outlined below) to continuously …
FinCEN Proposes Long-Expected AML Rule for Investment Advisers
By William Kelly On August 25th, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule applicable to investment advisers. At its core, the proposal seeks to extend anti-money laundering (“AML”) obligations imposed under the Bank Secrecy Act (“BSA”) to registered investment advisers. This proposal comes as little surprise, as the Treasury Department has long contemplated the extension of AML regulations to investments …
Bitcoin and U.S. Regulation
By Simon Riveles and Simon Cooke Bitcoin faces an uncertain regulatory future in the U.S. This uncertainty has led to the U.K.’s newest and most developed bitcoin exchange, Coinfloor, not accepting U.S. customers, at least initially. Bitcoin is a ‘peer to peer’ virtual currency created by a computer generated math based protocol. Bitcoin is an extremely risky and volatile investment with bitcoin’s value fluctuating by …